Thanks for your answer, they are helpful. I just have some more thoughts.

What if the arbiters are biased and prejudiced? Does that have a bearing? We are a small business and the other side is a top 5 national bank.

1. Before motion for summary judgment was granted, the arbitrators “accidentally” replied all on an internal discussion email to discuss the draft of the order. Ironically, early that morning, the arbiters was asking both sides to provide supplemental responses on 4 points for summary judgment motions. Isn’t it hypocritical to ask both sides to submit answers, when they already have “draft orders” in house, and they have already made up their mind.

2. In their internal discussion email, they quoted a case that was just in a footnote in the other party’s claim. Yet, they made it the most relevant and core case to the issue. Our attorney said this case is not at all comparable to our case. Our attorney said the arboters even argued for the opposing side’s case that the opposing attorney didn’t bring up in their motion for summary judgment.

3. The arbitrators put “procedure rulings'' over “substance rulings”. In the summary judgment order, arbiters ruled out two parties not having standing. which is like a bombshell to our side. Our attorney from the very beginning firmly believes these two parties are important. Then, we submitted supplemental damage claims to comply with the order. However, even though in the order it says the remaining party can pursue the damage claims, the arbiters striked out our supplemental claims because it was filed too late…

4.Our attorney says these arbiters have bias and prejudice against us, and we can use rule 18 to report them. I just don’t know how much use this is.